Help Protect Manatee Habitat

Please send a letter to the Army Corps of Engineers to impress upon
them, once again, the unnecessary and environmentally destructive nature of
a proposed project and ask that this project be denied. Please send your
letter as quickly as possible, as the deadline for comments ends September
19th.

We first contacted you about the SunWest Park Development and associated
SunWest Harbourtown project in Aripeka in Pasco County back in December
2011. The project included dredging a 3.1 mile long, 85-foot-wide channel
through Fillman’s Bayou to provide boater access to the Gulf of Mexico.
Unfortunately, a decision has yet to be made by the Army Corps of Engineers
(Corps) and we once again ask for your help to ensure this project is
denied.

On September 4, 2012, the Corps issued a new public notice for this
project after the applicant decreased the dredging width from 65 feet to 60
feet, increased the amount of submerged aquatic resources (SAV) to be
impacted from 11.8 acres to 28.8 acres, and created a new mitigation plan to
compensate for the impacts to SAV. These changes only reinforce our concerns
about the significant negative impact this project will have on manatees and
their habitat.

I am writing today to ask that the Corps deny the SunWest Park
application in Pasco County, Florida (SAJ-2007-05788). I am deeply concerned
with the proposed creation of a new 3.0 mile channel, which would contribute
to the calculated 28.8 acres of impact to submerged aquatic resources, in
addition to separate wetlands impacts. These impacts to submerged aquatic
resources are more than double the impacts proposed in the previous public
notice. Seagrass beds not only provide food and habitat to manatees, but to
many other commercially important species including gamefish and shellfish.
Even with the changes proposed in the latest public notice on September 4,
2012, the impacts to both manatees and their habitat would be unacceptable.

Of the many concerns I have about this project, I am specifically
concerned that a thorough review of the impacts this project may have on
manatees and their habitat was not performed. Under Section 7 of the
Endangered Species Act, the U.S. Fish and Wildlife Service (FWS) and the
Corps are charged with ensuring a project "is not likely to jeopardize the
continued existence of any endangered species or threatened species or
result in the destruction or adverse modification of habitat of such
species…" (ESA Sect. 7 (a)(2)). Yet there has been no effort by these
federal agencies to collect manatee sighting data in this area to determine
the effects that the project would have on manatees. However, there has been
significant data collected by the local citizens proving the importance of
this location to manatees. Although these sightings were not collected as
part of a scientifically designed and controlled study, these sighting data
are consistent with expected manatee use within the sphere of influence of
the proposed project and should be considered by the FWS as part of their
review for this project.

In addition, the FWS has not compensated for the decrease in the level of
protection manatees and their habitat would receive as a result of this
project. When the project was originally proposed, FWS concluded that if
certain measures were conditioned in the permit, including year-round idle
and slow speed zones near the facility, educational signage, seagrass
protection zones, boater education, and enforcement, manatees would be
adequately protected and the effect determination could be reduced to "not
likely to adversely affect the manatee." However, the majority of the speed
zones were not approved by the Florida Fish and Wildlife Conservation
Commission (FWC). When asked to consult again on the project, FWS did not
change their previous conclusion. It would seem that a reduction in the
protective measures conditioned to reduce the impacts to manatees should
have resulted in a change in the level of impact. However, this was not
seen.

Please deny this project as currently proposed. The project would put
manatees in serious danger and would cause permanent damage to aquatic
resources. The review by federal agencies was inadequate and the sighting
data by local citizens should be considered viable data. It is clear this
location is frequently used by manatees and is an important habitat for
their survival.

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